Additional Cause of Action – Breach of Contract

&Client& realleges foregoing paragraphs 1 through &Blank& and incorporate them herein by reference.

&InsCo& has breached the express terms of the Policy and duties under law by failing to provide the policy benefits described in the Policy as set forth herein.

Plaintiff has performed all the terms and conditions to be performed on its part pursuant to the Policy.

As a direct and proximate result of &InsCo&’s breach of the Policy terms, Plaintiff has been damaged in a sum in excess of the jurisdictional minimum of this court. Plaintiff will seek leave of court to amend this complaint to state the amount of damages when they have been ascertained.